PulseDNA Coach Privacy Policy

Effective date: 27 October 2026

PulseDNA Coach turns your Apple Health data into a daily readiness score and coaching plan. We built it so your health data stays on your devices. This policy explains what the app handles, why, who else is involved, and the choices you have.

1. Who we are

PulseDNA Coach is made by AdeptLabs. Adept Labs Technology Company Limited, Phu Tho Province, Vietnam, is the "controller" of the personal data described here.

2. The short version

3. What the app handles and why

3.1 Health data (stays on your device)

With your permission, the app reads these Apple Health types: steps, active energy, sleep analysis, heart rate, resting heart rate and heart rate variability (HRV). The Apple Watch app can save breathing sessions to Apple Health as mindful minutes if you allow it. The iPhone app does not write to Apple Health.

DataWhere it lives
Health data read from Apple HealthProcessed on your iPhone and Apple Watch. Not uploaded anywhere.
Readiness scores, insights, missions, journal entries, plans and historyA database on your device and the app's shared storage for widgets and Apple Watch
AI Coach conversationsOn your device only
Settings and preferencesOn your device

Health data is used only to provide the app's wellness features. It is never used for advertising or marketing, never sold, and never shared with third parties, as required by Apple's HealthKit rules. You can grant or revoke Health access at any time in the Health app or in iOS Settings › Health › Data Access & Devices.

3.2 On-device AI

AI Coach (on supported devices with Apple Intelligence), readiness scoring and the sleep, movement and heart models run on your device using Apple Foundation Models and Core ML. Your data is not sent to us or to any AI provider. AI Coach responses are informational and are not medical advice.

3.3 Usage statistics and crash reports (Google Firebase)

What:

What we never put in them: health data from Apple Health, readiness scores or anything else computed from your health data, journal text, AI Coach conversations, your name or contact details.

We don't use the advertising identifier (IDFA) and we don't track you across other companies' apps or websites.

Why: to find and fix bugs and crashes, and to understand which features are useful.

3.4 Subscriptions

PulseDNA Pro is sold through Apple's App Store. Apple processes your payment; we never see your payment details. The app receives a record of your purchase from Apple (StoreKit) to unlock Pro features and to restore purchases.

3.5 Support

If you email us, we use your email address and message to reply and to keep a record of the request.

3.6 Device permissions

The app asks before using Apple Health and notifications. Widgets, Live Activities, Siri, Shortcuts, Spotlight and Apple Watch features work on your devices.

PurposeLegal basis
Health features on your device (3.1, 3.2)Your explicit consent, given through Apple Health permissions (Art. 9(2)(a) GDPR). We do not receive this data.
Usage statistics and crash reports (3.3)Legitimate interests (Art. 6(1)(f)): keeping the app reliable and improving it. You can object (section 8).
Subscriptions (3.4), support replies (3.5)Contract (Art. 6(1)(b)), and legal obligation where records must be kept (Art. 6(1)(c))

5. Who processes data for us

ProviderWhat they doData
Apple Inc. / Apple Distribution InternationalApp Store payments and subscriptions, Apple Health, on-device AI. Apple acts under its own terms and privacy policy.Purchase data
Google LLC / Google Ireland Ltd (Firebase Analytics, Crashlytics)Our processor, under Google's data processing terms3.3

We do not sell personal data or share it for cross-context behavioural advertising. We may disclose data if the law requires it, to protect people's safety, or as part of a business transfer under this policy.

6. International transfers

Google may process data in the United States and other countries. Where data leaves the EU/EEA, the UK or Switzerland, we rely on the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) where the provider is certified, or otherwise on the European Commission's Standard Contractual Clauses.

7. How long we keep data

DataHow long
Data on your deviceUntil you delete it. Profile › Manage Data › Reset App Data deletes it; deleting the app removes it too.
Usage statistics2 months (our Google Analytics retention setting)
Crash reports90 days
Support emails24 months after the request is closed

8. Your rights

Depending on where you live, you have rights to access, correct, delete and receive a copy of your personal data, to restrict or object to its use, and to withdraw consent at any time.

Health data never leaves your device, so you control it directly through Apple Health and the app. For usage statistics, crash reports or anything else, email admin@adept-labs.com. Usage data is linked only to random app identifiers, so we may ask for details that help us find it. We reply within one month, or within 45 days for US state requests.

You can also complain to your data protection authority, for example the authority in your EU country or the UK Information Commissioner's Office.

US residents (including California): in the last 12 months we have collected identifiers (random app identifiers), internet or other electronic network activity (app usage and diagnostics), approximate location derived from IP, and commercial information (which subscription was purchased). We do not sell or share personal information as defined by the CCPA/CPRA, and we don't use sensitive personal information to infer characteristics.

9. Children

PulseDNA Coach is not directed at children under 13, or under 16 in the EU/UK, and we don't knowingly collect their personal data. If you believe a child has given us personal data, contact us and we will delete it.

10. Security

On-device data uses iOS data protection. Connections to Firebase use HTTPS. No system is perfectly secure, so keep your device passcode and Apple Account safe.

11. Not a medical device

PulseDNA Coach is a wellness app. It does not diagnose, treat or prevent any disease and is not a substitute for professional medical advice.

12. Changes

We'll update this policy when the app or the law changes, and change the effective date above. If a change is significant, we will tell you in the app before it applies.

13. Contact

Adept Labs Technology Company Limited, Phu Tho Province, Vietnam, admin@adept-labs.com